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. … Thus, the return of the unit in each case was to reflect that the original taxable supply was nullified, rather than representing a further taxable supply, so that the application of the s. 332 equivalent was confirmed. ...

. … Where a trust transfers property, it is a disposition. This is true even if the transfer is to a beneficiary or another trust with identical beneficiaries: subparagraphs (e)(i) to (iii) of the definition of disposition in s. 248(1). ...

. – whereas here the taxpayers had substantiated the existence of an RCA by obtaining an actuarial report to support the amount of contributions necessary to provide them with a reasonable pension on retirement. ...

In allowing the Crown’s appeal, Skolrood JA referred to his statement in GFL (at para. 60): I endorse the principle … in Preston that tax assumptions containing statements of mixed fact and law will not be invalidated simply on that basis if the factual underpinnings are clearly stated, there is no dispute about the legal principles and no prejudice results. ...

Furthermore, since in light of s. 251(6)(b) “a marriage ends on the death of one of the individuals … [t]o have the same rules apply to individuals in a common-law partnership, that relationship would also have to cease upon the death of one of the partners” (para. 44). ...

. … The Court cannot consider the control measures and contractual requirements of the client as intrinsic characteristics of a service contract, but must rather considers them as representative of HQ's desire to ensure that its supplier would be able to manufacture in sufficient quantity and supply it with concrete-cement in time and place, taking into account the remoteness of its construction site and the extreme geographical and meteorological conditions of a normal construction site. ...

. … She further found that the phrase "a right of any kind whatever" did not expand the ordinary meaning of "property" to include a non-exclusive, commonly held right to carry on a business, such as that held by the taxpayer. ...

. … This distinction means that under our Act it is only necessary to consider what the proceeds of the loan are to the borrower when they are received, and does not require an examination of what those loan proceeds are spent on. ...

Canada, 2018 FCA 121-- summary under Subsection 248(28) Summary Under Tax Topics- Income Tax Act- Section 248- Subsection 248(28) potential for double taxation under the ITA of NAL transactions The taxpayer, a Canadian exploration company, unsuccessfully argued that it was not subject to Part XII.6 tax on Canadian exploration expenses (“CEE”) that it had purported to renounce under the look-back rule- but which were now admittedly not eligible for look back because the flow-through share investors were non-arm’s length – because the reference in Part XII.6 to CEE that it “purported” to renounce under the rule referred only to expenses which had been validly rather than invalidly renounced under the look-back rule. ...

. … Despite his unusual lifestyle and his propensity to ridicule his opponents, the appellant was a serious businessman. ...